As we’ve previously reported, shortly after California amended its charitable solicitation laws to regulate Charitable Fundraising Platforms (“CFPs”), Hawaii enacted nearly identical provisions. In June 2025, Hawaii revised those laws again to address certain inconsistencies and extended the effective date to July 1, 2026. 

Hawaii’s Charitable Fundraising Platforms and Platform Charities FAQs explain that these requirements are designed to help donors understand where their contributions are going, what fees may apply, how long it may take for a charity to receive funds, and whether the charity has agreed to participate in the fundraising activity.

The new law defines a CFP very broadly as “any person that uses the Internet to provide an internet website, service, or other platform to persons in the State, and performs, permits, or otherwise enables acts of solicitation to occur.” The FAQs specifically state that “a platform may be a CFP even if it does not itself ask for the donation. It is enough that the platform permits, supports, or enables charitable solicitations to occur (HRS § 467B-1).” 

As in California, two new regulated classes were created:  “charitable fundraising platforms” and “platform charities.”  An entity is considered a CFP if it, among other things, offers round-up and donation-at-checkout program on an e-commerce site, offers a platform for charitable organizations to solicit and receive donations, and/or conducts commercial co-venture campaigns that are at least partially online with seven (7) or more charitable organizations in a calendar year. Unlike California, Hawaii’s law does not impose different requirements and/or disclosures depending on the type of solicitation being conducting. 

Note that there are two (2) key ways that  Hawaii’s law differs from California’s: (i) the definition of what it means for a charitable organization to be “good standing” in Hawaii, and (ii) a company must have permission from the charitable organization to solicit on its behalf.

So, what do you have to do if you’re deemed a CFP in Hawaii? You must, among other requirements:

• register by completing the online registration process and paying a $250 registration fee;
• renew annually by July 1st^; and file annual reports;
• only solicit on behalf of charitable organizations considered in good standing in Hawaii;
• have written consent from the charitable organization;
• keep funds in a  separate back account; and
• make required disclosures to consumers.

To minimize regulatory risk, it’s important for any organization facilitating charitable giving in Hawaii to evaluate its status under the amended law and update its processes accordingly.